FILED: NEW YORK COUNTY CLERK 02/03/ :26 AM INDEX NO /2015 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 02/03/2016

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1 FILED: NEW YORK COUNTY CLERK 02/03/ :26 AM INDEX NO /2015 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 02/03/2016 SUPREME COURT OF THE STATE OF'NEW YORK COUNTY OF NEW YORK IN RE: NEW YORK CITY ASBESTOS LITIGATION This Document Relates To: ANTHONY JULIANO and IRENE JULIANO, Plaintiff(s), : NYCAL ACKNOWLEDGEMENT OF RECEIPT - against - A.O. SMITH WATER PRODUCTS, et. al. Inde No.: /15 Defendant(s). : SIR/MADAM: Defendant FORD MOTOR COMPANY ("FORD"), by its attorneys, AARONSON RAPPAPORT FEINSTEIN & DEUTSCH, LLP, hereby acknowledges receipt of a copy of a SUMMONS and of plaintiffs' VERIFIED COMPLAINT dated November 18, 2015 in this action. FORD hereby answers the VERIFIED COMPLAINT by reference to its Standard Answer, Cross-Claims and Answer to Cross-Claims, dated April 18, 2002, filed pursuant to NYCAL Amended Case Management Order dated September 20, 1996, amended as of February 19, 2003, and raises each of the defenses and cross-claims contained in its Standard Answer, Cross-Claims and Answer to Cross-Claims, dated April 18, Dated: New York, New York February 1, 2016

2 Yours, etc. BY: Deirdre E. Tracey, Esgl AARONSON RAPPAPORT FEINSTEIN & DEUTSCH, LLP Counsel for Defendant FORD MOTOR COMPANY Office & P.O. Address 600 Third Avenue New York, NY To: BELLUCK & FOX, LLP Counsel for Plaintiff PLEASE SEE ATTACHED RIDER

3 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK IN RE: NEW YORK CITY ASBESTOS LITIGATION This Document Relates To: ANTHONY JULIANO and IRENE JULIANO,. Plaintiff(s), : : NYCAL NOTICE TO PRESERVE EVIDENCE - against - A.O. SMITH WATER PRODUCTS, et. al. Inde No.: /15 Defendant(s). : SIR/MADAM: PLEASE TAKE NOTICE, that pursuant to CPLR 3120 Section VIII of the Cas Management Order (CMO), Defendant Ford Motor Company ("Ford") hereby requests that al evidence relating to plaintiff's injury allegedly caused by eposure to asbestos containin products manufactured by Ford, including but not limited to any tumor, lung and pleural tissu which may become available, be preserved, and PLEASE TAKE FURTHER NOTICE that immediate notice be given to Ford when is anticipated that such tissue may become available; PLEASE TAKE FURTHER NOTICE that Ford hereby demands that it be notifie immediately of availability of plaintiff's tumor, lung and pleural tissue through any means, including performance of r a lung-related procedure, biopsy, death and/or any autopsy, an further that any such tissue be preserved;

4 PLEASE TAKE FURTHER NOTICE that Ford demands this preservation of tissue so that the nature and amount of asbestos fibers and asbestos bodies within the lungs, including parenchyma, pleura, and tumor of the plaintiff may be evaluated; PLEASE TAKE FURTHER NOTICE, that this is to be deemed a continuing demand; PLEASE TAKE FURTHER NOTICE, that failure to provide the aforesaid information, may result in a request for sanctions, including but not limited to a motion to strike plaintiff's pleadings, a request for an adverse inference charge and request of preclusion pursuant to the CPLR or any relevant statutory or case law. Dated: New York, New York February 1, 2016 Yours, etc. Deirdre E. Tracey, Esq. AARONSON RAPPAPORT FEINSTEIN & DEUTSCH, LLP Counsel for Defendant FORD MOTOR COMPANY Office & P.O. Address 600 Third Avenue New York, NY To: BELLUCK & FOX, LLP Counsel for Plaintiff PLEASE SEE ATTACHED RIDER

5 Anthony Juliano and Irene Juliano v. A.O. Smith Water Products Co. [nde No.: /15 File No.: Suzanne Halbardier, Esq. BARRY, MCTIERNAN & MOORE, LLP 2 Rector Street 14th Fl. New York, NY Counsel for CLEAVER-BROOKS CO., INC., f/k/a AQUA-CHEM, INC. Joseph Belluck, Esq. BELLUCK & FOX, LLP 546 5th Avenue 4th Fl. New York, NY Counsel for PLAINITFF(S) William Mueller, Esq. CLEMENTE MUELLER, P.A. 218 Ridgedale Avenue P.O. Bo 1296 Morristown, NJ Counsel for THE WILLIAM POWELL CO. John Fanning, Esq. CULLEN and DYKMAN, LLP 44 Wall Street New York, NY Counsel for GOULDS PUMPS, INC.; HOWDEN BUFFALO, INC., Individually and as Successor to FB STURTEVANT, THE HOWDEN BUFFALO GROUP and BUFFALO FAN; SPENCE ENGINEERING COMPANY, INC. Judith Yavitz, Esq. DARGER & ERRANTE YAVITZ & BLAU, LLP 116 East 27th Street 12th Fl. New York, NY Counsel for CERTAINTEED CORPORATION; UNION CARBIDE CORPORATION Richard Polley, Esq. DICKIE MCCAMEY & CHILCOTE, P.C. 2 PPG Place Suite 400 Pittsburgh, PA Counsel for TYCO FLOW CONTROL INC., Individually and as successor to KEYSTONE and GRINNELL CORPORATION; TYCO INTERNATIONAL (US), INC., Individually and as Successor to HANCOCK VALVES, KEYSTONE LONERGAN VALVES, GRINNELL CORPORATION Michelle D. Grady, Esq. ECKERT SEAMANS CHERIN & MELLOTT, LLC 10 Bank Street Suite 700 White Plains, NY Counsel for A.O. SMITH WATER PRODUCTS CO.; SUPERIOR LIDGERWOOD MUNDY CORP., a/k/a LIDGERWOOD MANUFACTURING CO, Individually and as successor to M.T. DAVIDSON CO.; TACO, INC. ( DOCX ) Cynthia Antonucci, Esq. HARRIS BEACH, LLP 100 Wall Street 19th Fl. New York, NY Counsel for ARMSTRONG INTERNATIONAL, INC.

6 Anthony Juliano and Irene Juliano v. A.O. Smith Water Products Co. Inde No.: /15 File No.: Mark S. Gaffrey, Esq. HOAGLAND, LONGO, MORAN, DUNST & DOUKAS, LLC P.O. Bo Patterson Street New Brunswick, NJ Counsel for YORK INTERNATIONAL CORPORATION, Individually and as successor to FRICK COMPANY George S. Hodges, Esq. HODGES WALSH MESSEMER & MOROKNEK, LLP 55 Church Street Suite 211 White Plains, NY Counsel for ELECTROLUX HOME PRODUCTS, INC., Individually and as Successor to TAPPAN and COPES-VULCAN; SPIRAX SARCO, INC. Kirsten Alford Kneis, Esq. K & L GATES LLP 599 Leington Avenue New York, NY Counsel for CRANE CO. Christopher P. Hannan, Esq. KELLEY JASONS MCGOWAN SPINELLI & HANNA, LLP 120 Wall Street 30th Fl. New York, NY Counsel for FMC CORPORATION, Individually and as successor in interest to NORTHERN PUMP COMPANY, COFFIN and PEERLESS PUMP COMPANY Philip O'Rourke, Esq. LEWIS BRISBOIS BISGAARD & SMITH, LLP 77 Water Street Suite 2100 New York, NY Counsel for KAISER GYPSUM COMPANY, INC.; PEERLESS INDUSTRIES, INC. { DOCX } Peggy L. Pan, Esq. KASOWITZ, BENSON, TORRES & FRIEDMAN, LLP Broadway 23rd Fl. New York, NY Counsel for HEIDELBERG USA, INC., Individually as Successor to POLAR MOHR; HEIDELBERG USA, INC., Individually as Successor in Interest to MERGENTHALER, LINOTYPE HELL and HARRIS- INTERTYPE Joseph Colao, Esq. LEADER & BERKON, LLP 630 Third Avenue 17th Fl. New York, NY Counsel for IMO INDUSTRIES, INC. f/k/a DELAVEL, INC., Individually and as Successor to TURBINE EQUIPMENT COMPANY; WARREN PUMPS, LLC, Individually and as successor to THE QUIMBY PUMP COMPANY Jim Lynch, Esq. & Scott Emery, Esq. LYNCH DASKAL EMERY, LLP 264 West 40 Street New York, NY Counsel for GEORGIA-PACIFIC CORP., Individually and as Successor to BESTWALL GYPSUM COMPANY; GOODYEAR CANADA, INC.; GOODYEAR TIRE & RUBBER CORP.

7 Anthony Juliano and Irene Juliano v. A.O. Smith Water Products Co. Inde No.: /15 File No.: Bob Malaby, Esq. MALABY & BRADLEY, LLC 150 Broadway Suite 600 New York, NY Counsel for DEZURIK, INC. Timothy Coughlan, Esq. MARON MARVEL BRADLEY & ANDERSON LLC 328 Newman Springs Road Red Bank, NJ Counsel for VELAN VALVE CORPORATION Anna DiLonardo, Esq. MARSHALL, DENNEHY, WARNER, COLEMAN & GOGGIN, P.C. 105 Maess Road Suite 303 Melville, NY Counsel for BORG-WARNER CORPORATION, by its Successor in Interest BORG WARNER MORSE TEC, INC. Donald R. Pugliese, Esq. McDERMOTT WILL & EMERY 340 Madison Avenue New York, NY Counsel for HONEYWELL INTERNATIONAL, INC., f/k/a ALLIED SIGNAL, INC., as successor-in-interest to THE BENDIX CORPORATION Kerryann Cook, Esq. MCGIVNEY & KLUGER, P.C. 80 Broad Street 23rd Fl. New York, NY Counsel for ATWOOD & MORRILL CO., INC., d/b/a WEIR VALVES & CONTROLS USA, INC.; DAP INC. k/n/a LA MIRANDA PRODUCTS CO., INC.; FALK CORPORATION; FLOWSERVE US, Solely as Successor to ROCKWELL MANUFACTURING COMPANY AND EDWARD VALVES, INC., NORDSTROM VALVES, INC., EDWARD VOGT VALVE COMPANY, and VOGT VALVE COMPANY; NASH ENGINEERING COMPANY; THE FAIRBANKS COMPANY; ZURN INDUSTRIES, INC. a/k/a and successor-in-interest to ERIE CITY IRON WORKS Marc Shanker, Esq. MORGAN, LEWIS AND BOCKIUS, LLP 101 Park Avenue New York, NY Counsel for ELLIOTT TURBOMACHINERY, INC.; GRINNELL CORP.; I.T.T INDUSTRIES, as Successor to BELL & GOSSETT { DOCX }

8 Anthony Juliano and Irene Juliano v. A.O. Smith Water Products Co. Inde No.: /15 File No.: Steven A. Weiner, Esq. O'TOOLE FERNANDEZ WEINER VAN LIEU, LLC 60 Pompton Avenue Verona, NJ Counsel for CLARK-RELIANCE CORPORATION, Individually and as Successor to JERGUSON Lisa M. Pascarella, Esq. PASCARELLA, DI VITA, LINDENBAUM, & TOMAZEWSKI, PLLC 2137 Route 35, 290 Holmdel, NJ Counsel for BIRD, INC., f/k/a BIRD & SON, INC.; RHEEM MANUFACTURING CO., INC. James W. Whitcomb, Esq. PHILLIPS LYTLE, LLP One Canalside 125 Main Street Buffalo, New York Counsel for DEAN PUMP DIVISION Paul Scrudato, Esq. SCHIFF HARDIN, LLP 666 Fifth Avenue Suite 1700 New York, NY Counsel for OWENS-ILLINOIS, INC. Michael Tanenbaum, Esq. SEDGWICK LLP One Newark Center, 16th Fl Raymond Blvd. Newark, NJ Counsel for CBS CORPORATION, a Delaware Corp., f/k/a VIACOM, INC., Successor by Merger to CBS CORPORATION, a Pennsylvania Corp., f/k/a WESTINGHOUSE ELECTRIC CORP., INC.; FOSTER-WHEELER LLC; GENERAL ELECTRIC CO. Ted Eder, Esq. SEGAL, MCCAMBRIDGE, SINGER & MAHONEY 850 Third Avenue Suite 1100 New York, NY Counsel for AURORA PUMP COMPANY; BW/IP INTERNATIONAL, INC., f/k/a BORG WARNER INDUSTRIAL PRODUCTS, Successor to BYRON JACKSON PUMPS; ECR INTERNATIONAL, INC., Individually and as Successor to DUNKIRK, DUNKIRK BOILERS and UTICA BOILERS; GARDNER DENVER, INC.; GREENE, TWEED & CO., LLP, Individually and asa Successor to PALMETTO PACKINGS; WEIL MC-CLAIN, a Division of The MARLEY-WYLAIN COMPANY { DOCX

9 -71 Anthony Juliano and Irene Juliano v. A.O. Smith Water Products Co. Inde No.: /15 File No.: Patrick J. Dwyer, Esq. SMITH, STRATTON, WISE, HEHER & BRENNAN, LLP Two Research Way Princeton, NJ Counsel for GOODRICH CORPORATION, f/k/a THE B.F. GOODRICH COMPANY, Individually and as Successor in Interest to GOODRICH-GULF CHEMICAL, INC., THE CLEVELAND PNEUMATIC COMPANY, A DIVISION OF THE PNEUMO ABEX CORP., a Wholly Owned Subsidiary of ABEX, INC. Justin Perri, Esq. STEPTOE & JOHNSON, LLP 1114 Avenue of the Americas New York, NY Counsel for METROPOLITAN LIFE INSURANCE CO. John J. Kot, Esq. WATERS, MCPHERSON & MCNEIL, P.C. 300 Lighting Way 7th Fl. Secaucus, New Jersey Counsel for RILEY POWER, INC., f/k/a BABCOCK BORSIG POWER, INC. and f/k/a RILEY STOKER CORPORATION d/b/a DB RILEY, INC. Edward Wilbraham, Esq. WILBRAHAM, LAWLER & BUBA 1818 Market Street Suite 3100 Philadelphia, PA Counsel for AIR & LIQUID SYSTEMS CORPORATION, as Successor by Merger to BUFFALO PUMPS, INC. Erik C. DiMarco, Esq. WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 150 East 42nd Street New York, NY Counsel for BURNHAM CORP.; CARRIER CORPORATION UNKNOWN COUNSEL SPX COOLING TECHNOLOGIES, INC., Individually and as Successor to MARLEY COOLING TECHNOLOGIES and MARLEY COOLING TOWERS ( DOCX )

10 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK IN RE: NEW YORK CITY NYCAL ASBESTOS LITIGATION This Document Relates To: ANTHONY JULIANO and IRENE JULIANO, Inde No.: /15 - against - A.O. SMITH WATER PRODUCTS, et. al. Plaintiff(s), Defendant(s). ACKNOWLEDGEMENT OF RECEIPT AND NOTICE TO PRESERVE EVIDENCE AARONSON RAPPAPORT FEINSTEIN & DEUTSCH, LLP Attorneys for Defendant FORD MOTOR COMPANY Office and Post Address 600 Third Avenue New York, New York TO: ALL PARTIES

11 STATE OF NEW YORK ) ss.: COUNTY OF NEW YORK ) AFFIDAVIT OF SERVICE BY MAIL Matthew J. Hayes, being duly sworn, deposes and says: that deponent is not a party to the action, is over 18 years of age and resides at Westchester, New York. That on the 1 day of February, 2016, deponent served the within ACKNOWLEDGEMENT OF RECEIPT AND NOTICE TO PRESERVE EVIDENCE on behalf of FORD MOTOR COMPANY upon: BELLUCK & FOX, LLP Counsel for Plaintiff PLEASE SEE ATTACHED RIDER at the address designated by said attorney(s) for that purpose by depositing a true copy of same enclosed in a postpaid, properly addressed wrapper, in an official depository under the eclusive care and custody of the United States Post Office within the State of New York. Matthew H yes Sworn to before me this 1st day of February, 2016 Gt-4 Notary Public SW) BELABED NOTPZ' PUBLIC 6TRITI Of NEN YORK LAO. #01 ileti eri-12 o 19 CPM111, CAA( s-med OZE-teg COMITY Our File No.: